3/18/2014

3/18/2014
RIC 2014
Digital Instrumentation and Controls:
Considerations of Embedded Digital Technology in Plant Equipment
Embedded Digital Devices:
Suggestions for an Improved Regulatory Framework
March 12, 2014
Mark J. Burzynski, President
NewClear Day, Inc.
General Problem Statement
• Draft Regulatory Guidance on Embedded Digital – Informs licensees that many new Instrumentation and Controls (I&C) and electrical components now contain embedded digital devices
– Reminds licensees of the compendium of regulatory guidance applicable to digital devices • Draft guidance does not define how a licensee can proceed with embedded digital devices
– However, the inference is that a formal license amendment is required
When can one make a change without prior NRC approval and when must one receive a licensee amendment?
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Implications
• Current digital regulatory guidance for digital license amendments was developed for major protection system retrofits – Document intensive
– Time consuming
– Expensive
• The wrong process can cause licensees to delay or forego plant improvements
I suppose it is tempting, if the only tool you have is a hammer, to treat everything as if it were a nail.
Abraham Maslow, 1966
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3/18/2014
Suggestion for Improved Tool 1
• Focused approach with better criteria for ‘simple’ devices to make a change without prior NRC approval
– Idea comes from recently approved efforts in NEI 13‐10 to address cyber security issues ‘simple’ devices with a focused approach
• Industry efforts to improve NEI 01‐01 should consider lessons learned from NEI 13‐10 to provide a focused regulatory approach for ‘simple’ devices
Goal would be clear guidance for installation of ‘simple’ digital devices without prior NRC approval
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Suggestion for Improved Tool 2
• Simplify digital license amendment process outlined in DI&C‐ISG‐06 to define information necessary to address ‘limited functionality’ digital devices – Idea comes from simplified process used for one license amendment for reactor trip breakers with embedded digital devices and IAEA Draft Safety Guide DS‐431
• Industry workshop approach could be used to tailor DI&C‐ISG‐06 using US and international experience
Goal would be simpler process would allow one to process license amendments in shorter time with less resource commitments from all
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Suggestion for Improved Tool 3
• Develop NRC‐approved generic assessment process for ‘smart’ devices with third party certification
– Idea comes from similar generic guidance in EPRI‐106439 and European efforts with third party certification processes as basis for regulatory acceptance
• Coordinated industry effort to develop criteria for acceptance of third party certification for ‘smart’ devices in commercial grade dedication
Goal would be generic Quality Assurance program element for adoption by licensees for commercial grade dedication without prior NRC approval
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3/18/2014
Suggestion for Improved Tool 4
• Revise 10 CFR 50.59 to reflect graded approach for ‘simple/limited functionality/smart’ digital devices
– Idea comes from last change to 50.59 when PRA technology advances made the ‘no increase’ language impractical to manage (The famous Diaz ‘Zero Factor’ RIC speech)
• Industry and NRC tackled the challenge from Commissioner Diaz to find a practical solution
Goal would be to revise 50.59 language for ‘failure modes’ to better address ‘simple/limited functionality/smart’ digital devices
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Summary
• Technology changes are always forcing us to reconsider old paradigms and embedded digital devices are just one more driver of change
• Other people in our industry are addressing embedded digital devices in a variety of ways
• A good incubator of ideas exist to help us address embedded digital devices in a practical manner
We are all faced with a series of great opportunities brilliantly disguised as impossible situations.
Charles R. Swindoll
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